The question he asked at Quakecon 2010 was actually "who has spent at least $20 on the Android app store?"[1], not just on a single game. Your catch-22 scenario still holds, though I think the quantity and quality of free apps in the Android app store has also raised the bar for pay apps.

[1] http://www.youtube.com/watch?v=1_SdC8LVODY&feature=playe...